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- "full_text": "Case 1:20-cr-00330-PAE Document 759 Filed 08/10/22 Page 257 of 267 2285 LCAVMAX8\nsuggested. I think in the press of business over the last 24 hours, that has not yet been discussed between the two sides.\nMS. MOE: That's correct, your Honor.\nWe haven't had a chance to confer about that issue. We have begun discussing that internally and are thinking through that carefully. We're not in a position to make a representation about our position at this juncture, but that's very much top of mind and we'll be working diligently on that issue over the break.\nTHE COURT: Okay.\nMS. MENNINGER: And just as a preview, your Honor, there may be some others like that. As your Honor is aware, things came up during the course of testimony, and we will confer with the government about that with respect to other attorneys as well.\nMS. MOE: I'm sorry, your Honor. I'm not sure I'm following that.\nMS. MENNINGER: There are other matters that may give rise to the need for attorney testimony or probably more likely a stipulation about similar issues. And we would like to confer with the government first before briefing them. But I wouldn't -- our witness list may have other attorneys' names on them that have an asterisk by it saying subject to briefing and approval by the Court. I don't want anyone to believe we haven't understood the Court's prior statements on this topic.\nSOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 DOJ-OGR-00013848",
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- "content": "suggested. I think in the press of business over the last 24 hours, that has not yet been discussed between the two sides.\nMS. MOE: That's correct, your Honor.\nWe haven't had a chance to confer about that issue. We have begun discussing that internally and are thinking through that carefully. We're not in a position to make a representation about our position at this juncture, but that's very much top of mind and we'll be working diligently on that issue over the break.\nTHE COURT: Okay.\nMS. MENNINGER: And just as a preview, your Honor, there may be some others like that. As your Honor is aware, things came up during the course of testimony, and we will confer with the government about that with respect to other attorneys as well.\nMS. MOE: I'm sorry, your Honor. I'm not sure I'm following that.\nMS. MENNINGER: There are other matters that may give rise to the need for attorney testimony or probably more likely a stipulation about similar issues. And we would like to confer with the government first before briefing them. But I wouldn't -- our witness list may have other attorneys' names on them that have an asterisk by it saying subject to briefing and approval by the Court. I don't want anyone to believe we haven't understood the Court's prior statements on this topic.",
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